PPI DEADLINE UPDATE. Julia Cooper, Independent Chair, Alliance of Claims Companies
|
|
- Edward Bernard Benson
- 5 years ago
- Views:
Transcription
1 PPI DEADLINE UPDATE The Alliance of Claims Companies (ACC) was established to provide a collective viewpoint to the Carol Brady review in 2015 and is now the biggest representative voice of the financial claims management industry. Julia Cooper, Independent Chair, Alliance of Claims Companies When we formed, the threat to our industry was threefold the Carol Brady Review into future regulation, the proposed time bar and associated Plevin rules, and the potential of the introduction of a fee cap. We met with Carol Brady during her work and we have seen her recommend transition to the Financial Conduct Authority (FCA) in terms of regulation, and work for that has started within the FCA. We engaged with the transition team to ensure the best outcome for the industry as this moved forward though it has to be said this isn t a process in which the FCA are showing any appetite for a speedy conclusion, and their transition team has now been disbanded. We still await the MoJ s decision in regard to a fee cap, but we now know the FCA s thinking in relation to the time bar and Plevin and it is therefore vital that our members, which currently represent around half of all current claims volume in the market consider carefully the FCA s announcement on the PPI deadline as well its guidance on Plevin cases; what it means for members and their processes, and the impact on their previous and future clients. It is clear that our members will need to come together to decide upon a coherent and timely strategy in response to this announcement, which may result in a judicial review of the FCA s policy announcement (PS17/3). What is clear is that we do not feel that a time bar is in the best interests of consumers, and does not allow the greatest opportunity for them to seek access to justice. It is for that reason that we in the ACC will reserve the right to take whatever action is necessary to safeguard consumers. As I alluded to, it is likely that the fee cap announcement will follow shortly, which may also prompt the ACC to gather a collective response and we await the details of that in due course. Since there is a lot to digest, we are delighted to be working alongside Scott Robert to produce this practical guide for members and potential members on the operational impact of the deadline and how to take their Plevin cases forward. If you wish to know more about the work of the ACC then do visit our website or please drop me (julia.cooper@allianceofclaimscompanies.co.uk) or Simon Evans our Chief Executive an (simon.evans@allianceofclaimscompanies.co.uk), as we are here to represent the industry and would welcome new members to help us drive forward our aim of aiding consumer confidence in claims management companies.
2 Payment protection insurance complaints: feedback on CP16/20 and final rules and guidance The Financial Conduct Authority ( FCA ) have now released their final rules and guidance on two consultation papers concerning imposing a deadline on Payment Protection Insurance ( PPI ) (and associated) claims and claims concerning unfair commission. Scott Robert, FinTech, Regulatory Risk, Compliance and Strategy experts Payment Protection Insurance (and associated) claims deadline Now the Financial Conduct Authority ( FCA ) have confirmed the date of the deadline will be 29th August 2019, new and former PPI claims can only be submitted up until this date. Claims Management Companies ( CMC ) will have to ensure that if they submit a claim on behalf of a consumer that they must do so before this time period. The announcement of the deadline may mean that firms decide to increase the amount of marketing undertaken, PPI (and associated) claims deadline or make reference to the deadline in their marketing communications. CMCs should ensure that all of their financial promotions are reviewed against the Conduct of Authorised Persons Rules 2014 and specifically check that they are clear, transparent, fair and not misleading, as well as reviewing compliance against the relevant advertising Code of Practice. We anticipate an update in regard to the FCA s policy statement to appear on the Claims Management Regulator s ( CMR ) website, with specific emphasis on the deadline date; there is also likely to be something issued by the Advertising Standards Authority ( ASA ) at a later stage. It is important to bear in mind that high pressure tactics using the deadline date are still prohibited and cannot be adopted by any means, including: By way of telephone; Through any other form of direct marketing; On websites; In client packs. The FCA have also commented on the fact that customers are not obliged, nor do they need to go through a CMC to re-claim any PPI; it is important to maintain the current guidance in respect of informing any prospective or former clients that they can indeed make a claim themselves directly to the lender. The FCA are implementing a high-profile consumer communications campaign, including requiring lenders to inform clients who have had a rejected PPI claim, but are eligible to compensation due to an unfair relationship. Firms must also give consideration to data consents when attempting to re-contact consumers who they think have an additional claim or a claim in respect of unfair commissions (please see the General Data Protection Regulation ( GDPR ) section below for further information). Even if a consumer has previously held a contract with the CMC, there are two consents to consider. The first, known as data processing consent, is concerned with whether a firm still has the right to hold and process the consumer s personal data for the purposes of marketing.
3 The second is concerned with the Privacy and Electronic Communications (EC Directive) Regulations 2003 ( PECR ), and focuses on the consent required to contact the consumer by various means including where they are registered with the Telephone Preference Register ( TPS register ) by , by SMS and by way of automated voice calls. It is therefore advisable for CMCs to check their general data consents, and before contacting any consumer by phone to check the number against the TPS register, and against internal do not contact lists. The CMR have recently argued that by registering on the TPS after consent was given to a firm they have essentially withdrawn their consent. There are no rules in respect of how long consent lasts although the CMR have previously adopted historic guidance from the Information Commissioner s Office ( ICO ) which advised that consumers should not be contacted if consent is over six months old. In practice, the duration of a consumer s consent is entirely dependent on what the consumer intended when they gave the consent, and whether action has been taken subsequent to that consent to revoke it. The wording of a firm s own consents should be closely examined to understand the likely duration of consent for their own clients. In addition to the above, from April 2017 the ICO will have the power to hold Directors directly responsible for any breach by their firm of PECR. In addition to the above, on 25th May 2018 the GDPR regime will be brought into force which will replace the Data Protection Act This will require significant changes to the management of personal data including the management of consents. Given that firms will likely want to use existing data well into 2019 consideration should be given now to GDPR, and required changes applied to how consents are obtained, including the wording of those consents, together with making the required changes to data processing activities. Further information is provided at the end of this guidance note. The majority of the narrative about the deadline does not reveal anything further than the initial consultations, but please contact Scott Robert if you do have any questions. Our team will be contacting existing clients next week to discuss potential changes required to business models. Claims for unfair commission-plevin v Paragon Personal Finance Ltd ( Plevin ) The final rules and guidance in respect of Plevin complaints are much more comprehensive. We have provided a summary of these and what this could mean for CMCs. The rules and guidance reiterate the content of consultation in respect of who is able to claim. There is a useful infographic¹ which has been published by the FCA in respect of the release of the policy statement. It goes into further detail of how redress for these cases should be calculated, what should be included, and how consumers will know if they may be affected by Plevin. The New Rules The rules make clear that to be a valid complaint the tipping point for having a legitimate Plevin claim is where commission is over 50% of the total value of the policy. The FCA have confirmed that the failure to disclose commission to consumers was not required by their insurance conduct of business rules (ICOB/ICOBS), so a firm s (i.e. the lender) failure to disclose the commission was not in breach of the FCA s specific rules. A consumer (or CMC) could therefore not submit a complaint solely on this basis. ¹
4 As a result of this, the FCA have confirmed that they do not expect firms to proactively review previously rejected PPI complaints about credit agreements falling under s.140a-b of the Consumer Credit Act 1974 against their new rules and guidance (i.e. Plevin complaints). The FCA have also stated that they would not expect firms to re-open a complaint where a consumer previously complained explicitly about the non-disclosure of commission on their PPI policy and the firm considered this but did not uphold the complaint. So when reviewing previously rejected complaints, CMCs will need to ensure this is checked thoroughly. It is also worth noting that the FCA expect firms to assess new complaints for Plevin considerations even where the complainant does not expressly raise the issue, or provide few details about it, or show little understanding of it. Considering all of the above, CMCs therefore are likely to need to substantiate the commission amount prior to being able to submit a complaint solely based on Plevin. It is not clear at this stage how they could do this but it is worth noting that solicitors will not have the same requirement to do this should their client wish to make a Plevin complaint. The FCA have confirmed that consumers will remain free to go to the courts to make a complaint through legal means. The rules for assessing Plevin complaints will come into force on 29th August Until this time, lenders are still able to respond saying the complaint is on hold awaiting final rules (the same will apply with the Financial Ombudsman Service ( FOS )). Some further considerations on Plevin cases apply: This would not apply to PPI sales made before 2005 or to credit agreements from lenders that did not carry out insurance mediation before 1st April 2014; First charge mortgage PPI claims will not fall under these rules as the activity did not fall under the relevant provision of the Consumer Credit Act, unless it was sold prior to 2004 and does not conclude before April 2007; We anticipate that second charge mortgage PPI claims, where the finance was taken out prior to 21st March 2016, will fall under these rules as secured loans fell under the scope of the Consumer Credit Act prior to this date; If a CMC is taking on a Plevin case it must ensure it has the proper authority to bring a Plevin complaint on behalf of clients and observe appropriate standards. The FCA do not state this specifically but this is effectively required to comply with the Conduct of Authorised Persons Rules Further authority from the client may be required in this regard; All resubmitted complaints will be subject to the fee cap (if and when this comes in) even where the client had previously signed a contract with a CMC on different terms. The FCA expects the proposed fee cap to be expedited and we can only presume discussions in this regard have been held with the Claims Management Regulator; The Definition of a Credit Agreement as detailed by the FCA (and therefore the only kind of agreements that can have a Plevin complaint submitted) is as follows: it is between an individual (the debtor ) and any other person (the creditor ) under which the creditor provides the debtor with credit of any amount; and an order under section 140B of the CCA could be made in relation to it. In summary, orders can be made under section 140B of the CCA in relation to credit agreements except where: the exclusion under section 140A(5) of the CCA applies (this relates to regulated mortgage contracts and regulated home purchase plans); or the agreement was made before 6 April 2007 and became a completed agreement before 6 April Current rules and guidance do not appear to provide any further compliance requirements at this stage. If a CMC is attempting to make a Plevin claim it is important to include a clear, unambiguous explanation around why the client is submitting a claim along with the rationale behind this (i.e. the commission of over 50%). Importantly the existing Conduct of Authorised Persons Rules apply including General Rule 2(b) requiring firms to substantiate and evidence the basis of the claim, and that representations are specific to each claim and are not fraudulent, false or misleading.
5 It may be that the lender discloses that the consumer has paid over 50% in commission in their requirement to write to their consumers, but we believe this is unlikely and the summary below covers the details provided in the FCA statement. Lenders obligations to notify consumers Given that the FCA did not require commission disclosure in their ICOB/ICOBS rules, they have decided it would be inappropriate to require or otherwise expect firms to proactively review, or take other proactive actions in respect of all past PPI policies and sales which fall within the scope of s.140a(b) CCA. However, it has therefore confirmed lenders must write out to consumers who may be affected. We have included below a list of the relevant areas of the FCA statement that cover the requirement for lenders to notify consumers affected by Plevin. However, it is not clear what the exact content must be and there does not appear to be an obligation to include the commission amount. The FCA will add to its finalised package of measures a rule requiring firms that sold PPI to write, to those of their previously rejected mis- selling complainants who are in scope of s.140a CCA, with appropriate messaging about the right of those consumers to complain again in light of Plevin. The FCA anticipate that 1.2m consumers will be in the scope of this mailing. Consumers should be included in the mailing where they: have or had a PPI policy where the credit agreement is in the scope of s.140a and, in respect of this policy, as at 29 August 2017, they had: made a complaint about mis-selling but the firm had rejected this, and either not referred the complaint to FOS referred the matter to it but FOS had rejected it, and/or not previously made a complaint about undisclosed commission that the firm or, where applicable, FOS had previously considered or otherwise indicated in writing that it would consider. The content of letters must include: an explanation that the consumer can make a further complaint, if they wish to, in relation to a failure to disclose commission a reference to the deadline and the identity of the CCA lender (where this is known to the seller or can be identified by them following reasonable steps) reference to the availability of further information about arrangements for making a further complaint on the FCA s PPI website, or by contacting the FCA s PPI contact centre. The Calculation of Redress CMCs should be aware that although they may not want to (or be able to) submit new Plevin complaints, where they have one on hold there is an obligation to clients to ensure that they have been paid the correct amount of redress. The FCA have confirmed that lenders reviewing complaints should presume that the failure to disclose commission gave rise to an unfair relationship under section 140A of the CCA if the anticipated profit share, plus the commission that was known or reasonably foreseeable at the time of the sale, was more than 50% (this figure would include Insurance premium tax) of the total amount paid in respect of the PPI policy. If the case is considered to be unfair the redress must include: the difference between the commission the customer paid (e.g. 70% of the premium) and (the proposed tipping point of) 50% of the premium paid (i.e. 20% of premium in this example); plus the historic interest the customer paid on that portion of the premium (where relevant) (ie the interest paid on the 20%); plus annual simple interest at 8% on the sum of the above.
6 Other points of note: Sums rebated to a consumer when, for example, they cancelled a single premium PPI policy early, can be partly included in, and so will reduce, any redress due under an additional or associated unfair commissions claim. The FCA have given examples of calculations in Appendix 2 of their paper and we would suggest reviewing these to provide an idea of how lenders should be calculation redress for different elements of a claim in the 2 stage process outlines by the FCA. Profit Share The FCA define profit share as Arrangements (includng contractuals) that firms have to potentially receive back some of the amount paid in relation to a PPI policy which had initially gone to the insurer. For example, such arrangements might include amounts paid to cover potential claims on policies, but which remain unspent after a fixed period, for example because actual claims did not exceed certain levels. They have decided that the disclosure of profit share would generally have been likely to impact the consumer s thinking alongside any commission (or, in some cases, a profit share alone). So the FCA are including it in the 50% tipping point on the basis it would run with the grain of Plevin and the fairer to the consumer. GDPR Further to the data consent considerations referred to above CMCs must consider the GDPR s stricter interpretation of consent. The consumer will need to have consented to the specific product the CMC is contacting them about and it is likely to need to have specific consent for a Plevin complaint. Without further comment, guidance or rules from the CMR we do not yet know exactly what the Regulator will expect of CMCs with regard to GDPR, but as and when the CMR do publish guidance we will provide further analysis. However the ICO are currently conducting a consultation on GDPR, the results of which will be communicated as soon as these are available. Importantly firms should act now, on the basis of the content of the GDPR, to begin reviewing their business. Awaiting finalised guidance from Regulators is likely to mean that it has been left too late. Preparation for the GDPR implementation is key to securing that customer data can be used in expanding a firm s service offering and we are currently working with firms that are gearing up for the future of the industry. Scott Robert will be releasing briefings regularly on how CMCs will need to prepare for the implementation of GDPR and the future of claims management. You can subscribe to our mailing list by ing enquiries@ scottrobert.co.uk with your details. For Further Information If there is anything that you would like to discuss further, please let one of the team at Scott Robert know by calling or ing enquiries@scottrobert.co.uk and we will be happy to talk with you.
CP15/39 Rules and guidance on payment protection insurance complaints
Telephone: 020 7066 9346 Email: enquiries@fs-cp.org.uk Lauren Dixon & Julian Watts Specialist Supervision Division Financial Conduct Authority 25 The North Colonnade Canary Wharf London E14 5HS 26 February
More informationPutting Consumers First. Code of Practice The Professional Financial Claims Association. All rights reserved.
Putting Consumers First Code of Practice 2016 The Professional Financial Claims Association. All rights reserved. Introduction The members of the Professional Financial Claims Association (PFCA) wish to
More informationThe Information Commissioner s response to the FCA s Credit card market study: consultation on persistent debt and earlier intervention remedies
The Information Commissioner s response to the FCA s Credit card market study: consultation on persistent debt and earlier intervention remedies The Information Commissioner has responsibility for promoting
More informationAppendix 3 Handling Payment Protection Insurance complaints
Appendix Handling Payment Protection Insurance.1 Introduction App.1.1 Application (1) This appendix sets out how: (a) a firm should handle relating to the sale of a payment protection contract by the firm
More informationPPI complaints end 29 August 2019
PPI complaints end 29 August 2019 What will you decide?? Large print version Making your decision about PPI We re the Financial Conduct Authority. We regulate the financial sector and are here to protect
More informationOmbudsman s Determination
Ombudsman s Determination Applicant Scheme Respondents Mrs Y Berkeley Burke SIPP (the SIPP) Berkeley Burke Outcome 1. I do not uphold Mrs Y s complaint and no further action is required by Berkeley Burke
More informationFinancial Ombudsman Service: strategic plans and budget for 2019/2020
Financial Ombudsman Service: strategic plans and budget for 2019/2020 30 January 2019 Introduction The BSA is pleased to respond to the consultation by the Financial Ombudsman Service on its strategic
More informationUnified Code of Conduct For Financial Claims Management Companies
Unified Code of Conduct For Financial Claims Management Companies Issued: Monday 22 nd October 2012 Introduction This unified Code of Conduct for Financial Claims Management Companies (the Code) is a code
More informationTerms of Engagement ( Agreement )
Terms of Engagement ( Agreement ) The Claims Guys Limited (TCG), Lynnfield House, Church Street, Altrincham, Cheshire, WA14 4DZ is registered in England (Company No. 06821134) and is regulated by the Claims
More informationThese terms of business (the Terms ) explain the entire rights and obligations of You and Us regarding the provision of our Services.
Investor Compensation (UK) Limited - Terms and Conditions PPI These terms of business (the Terms ) explain the entire rights and obligations of You and Us regarding the provision of our Services. You should
More informationABI response to ICO consultation on GDPR consent guidance
1 31 March 2017 ABI response to ICO consultation on GDPR consent guidance About the ABI: The Association of British Insurers (ABI) is the leading trade association for insurers and providers of long-term
More informationThis final decision is issued by me, Nimish Patel, an Ombudsman with the Financial Ombudsman Service.
This final decision is issued by me, Nimish Patel, an Ombudsman with the Financial Ombudsman Service. My colleague, Ombudsman Graham Booth, issued a Provisional Decision on 13 July 2017 ( the Provisional
More informationPlease complete: Please note the Contract comprises of the Pre-Contract Information, Terms & Conditions and Letter of Authority
Please complete: GG 1 x Account Details GG 1 x Reasons For Complaint GG A Letter of Authority for each company Q. I don t have any account numbers or documentation, can I still claim? A. Yes! All you need
More informationApplication to Make a Claim
Application to Make a Claim YOUR CONTACT DETAILS Main Phone Number Complete a separate application and letter of authority for each claim. Sign and post using the enclosed pre-paid envelope. Relax, we
More informationPepper Money Terms of Business for Intermediaries
Pepper Money Terms of Business for Intermediaries 1 INTERPRETATION For purposes of these Terms of Business for Intermediaries, the following expressions have the meanings specified below: Applicable Laws
More informationThese terms of business (the Terms ) explain the entire rights and obligations of You and Us regarding the provision of our Services.
Investor Compensation (UK) Limited - Terms and Conditions PPI These terms of business (the Terms ) explain the entire rights and obligations of You and Us regarding the provision of our Services. You should
More informationDebt collection. Myths and facts
Debt collection s and facts The following are statements, comments and opinion expressed as fact on various customer forums, and the extent to which these statements have any basis of truth. Selling a
More informationBar Council response to the Claims Management Regulation Consultation: Cutting the costs for consumers Financial Claims consultation paper
Bar Council response to the Claims Management Regulation Consultation: Cutting the costs for consumers Financial Claims consultation paper 1. This is the response of the General Council of the Bar of England
More informationFCA sets 29 August 2019 as final cut-off date for PPI complaints
FCA sets 29 August 2019 as final cut-off date for PPI complaints Financial Conduct Authority Policy Statement PS 17/3 Payment protection insurance complaints: feedback on CP16/20 and final rules and guidance
More informationPre Contract Guide - Payment Protection Insurance
Pre Contract Guide - Payment Protection Insurance It is important to us that you make the right decision. We therefore provide guidance about what we do, how we work and our fee. PPI Advice Ltd does not
More informationMONTHLY REGULATORY UPDATE JANUARY 2017
MONTHLY REGULATORY UPDATE JANUARY 2017 6 February 2017 The following is a summary of the pronouncements issued since our last regulatory update for the financial services sector issued on 3 January 2017.
More informationCustomer Privacy Notice Edition
Customer Privacy Notice - 2018 Edition How Precise Mortgages uses your personal data 0800 116 4385 precisemortgages-customers.co.uk Contents About us 3 Who this privacy notice applies to 3 Why we are providing
More informationSME Business Lending. Application Form Republic of Ireland.
SME Business Lending Application Form Republic of Ireland www.bankofireland.com/business Bank of Ireland is regulated by the Central Bank of Ireland. NOTICE: Under the Credit Reporting Act 2013 lenders
More informationtel: Fighting Your Corner
www.yourmoneyclaim.co.uk tel: 01254 822880 Fighting Your Corner BILLIONS set aside in compensation for mis-sold PPI & bank accounts PPI DEADLINE NOW SET The Financial Conduct Authority has set a deadline
More informationAlan Boswell & Company Ltd Terms of Business Agreement
Alan Boswell & Company Ltd Terms of Business Agreement Alan Boswell Financial Planners is the trading style of Alan Boswell & Company Ltd, which is authorised and regulated by the Financial Conduct Authority
More informationUK Asset Resolution Limited Group. Interim Financial Report
UK Asset Resolution Limited Interim Financial Report 30 September 2017 UK Asset Resolution Limited Group Interim Financial Report for the 6 months to 30 September 2017 30 November 2017 UKAR Interim Financial
More informationFlairford Securities Limited trading as Brunel Franklin, (CRM 13067), wishes to make representations
Claims Management Regulation Review Ministry of Justice 10 th Floor (10,11) 102 Petty France London SW1H 9AJ Dear Sirs Review of Claims Management Regulation Flairford Securities Limited trading as Brunel
More informationSign & complete your Letter of Authority. Sign your Letter of Engagement. Return ALL signed forms in the pre-paid envelope
Reclaiming PPI since 2010 Thank you for choosing Red Star to investigate your potential claim for mis-sold PPI. Below is your 4 step process that must be completed to ensure our investigation can start
More informationFinancial Services Guide
Financial Services Guide Date of issue: 1 January 2018 Financial Services Partners Pty Ltd Level 23, 242 Pitt Street Sydney, NSW 2000, Australia AFSL No. 237590 ABN 15 089 512 587 T 1800 006 216 W www.fspadvice.com.au
More informationTerms Of Business - Personal
Terms Of Business - Personal F Berry (Leyland) Ltd t-a Berry Insurance Brokers 149 Towngate Leyland Preston Lancashire PR25 2LH is an independent broker. We are authorised and regulated by the Financial
More informationTHIS HANDY LITTLE GUIDE EXPLORES THE BASICS OF CREDIT SCORING AND CREDIT REPORTING IN AUSTRALIA. TABLE OF CONTENTS
CREDIT MADE SIMPLE THIS HANDY LITTLE GUIDE This handy little guide explores the basics of credit scoring and credit reporting in Australia. EXPLORES THE BASICS OF CREDIT SCORING AND CREDIT REPORTING IN
More informationCitizens Advice Scotland Scottish Association of Citizens Advice Bureaux
Citizens Advice Scotland Scottish Association of Citizens Advice Bureaux www.cas.org.uk Financial Conduct Authority Detailed proposals for the FCA regime for consumer credit Response from Citizens Advice
More informationFinal report by the Complaints Commissioner dated 2nd January 2018 Complaint number FCA00269
Final report by the Complaints Commissioner dated 2 nd January 2018 Complaint number FCA00269 The complaint 1. On 24 July 2017 you asked me to investigate a complaint about the Financial Conduct Authority
More informationFINAL NOTICE. The Co-operative Bank plc. FSA Reference Number: Address: Date: 4 January ACTION
FINAL NOTICE To: The Co-operative Bank plc FSA Reference Number: 121885 Address: 13 th Floor, Miller Street, Manchester, M60 0AL Date: 4 January 2013 1. ACTION 1.1. For the reasons given in this Notice,
More informationInquiry into the Powers and Operations of the Inland Revenue Department
A.5 Government to the Report of the Finance and Expenditure Committee on Inquiry into the Powers and Operations of the Inland Revenue Department Presented to the House of Representatives in accordance
More informationchief ombudsman & chief executive s report
chief ombudsman & It s approaching 20 years ago now that discussions were underway about setting up a single ombudsman for financial services. This would replace eight existing schemes each covering individual
More informationWHAT DOES THE INSURER HAVE TO PROVE IN A FRAUD INVESTIGATION? WHAT CAN I DO IF I AM INVESTIGATED FOR FRAUD ON AN INSURANCE CLAIM?
WHAT CAN I DO IF I AM INVESTIGATED FOR FRAUD ON AN INSURANCE CLAIM? This fact sheet is for information only. It is recommended that you get legal advice about your situation. Investigations by insurers
More informationMr and Mrs F accepted the adjudicator s assessment but Aviva did not agree with this assessment and asked for an ombudsman s decision.
complaint This complaint is about two single premium payment protection insurance ( PPI ) policies sold in conjunction with two loans, taken out in 2001 and 2002. Mr and Mrs F say that Aviva Insurance
More informationPre-contract credit information
Pre-contract credit information Standard European Consumer Credit Information PLEASE RETAIN FOR YOUR RECORDS 1. Contact details Creditor. Address. Telephone number(s). Web address. PRE-CONTRACT CREDIT
More informationSnapshot Own Motion Inquiry Investigation of Claims and Outsourced Services
2014 General Insurance Code of Practice Snapshot Own Motion Inquiry Investigation of Claims and Outsourced Services 1 May 2017 Page 1 of 16 Chair s message I am proud to present the Code Governance Committee
More informationDirect line: Local fax:
Direct line: 0207 066 3100 Local fax: 0207 066 3101 Email: martin.wheatley@fca.org.uk Financial Conduct Authority 25 The North Colonnade Canary Wharf London E14 5HS Andrew Tyrie MP Chairman of the Treasury
More informationPrint Name: Signature: Date:
McCarney Financial Services Ltd. Terms of Business Effective 22 nd May 2018. These terms of business set out the general terms under which our firm will provide Financial Services to you. It details the
More informationour plans for the year ahead
our plans for the year ahead 2018/2019 Financial Ombudsman Service our plans for the year ahead 2018/2019 contents what s in our plans for the year ahead 2018/2019 about us 1 chief ombudsman s foreword
More informationFixed Deposit Account Terms & Conditions
Fixed Deposit Account Terms & Conditions 1 Introduction and about us 1.1 These Fixed Deposit Account Terms and Conditions set out the terms and conditions that apply to fixed term deposit accounts with
More informationEuropean Union General Data Protection Regulation
European Union General Data Protection Regulation Policy 25 May 2018 Bendigo and Adelaide Bank Limited ABN 11 068 049 178 General Data Protection Regulation (GDPR) Application This GDPR section of our
More informationResponse from [the Complainants] Compensation for distress and inconvenience
Ombudsman response to comments on provisional determination CIFO Reference Number: 16-000198 Complainants: [Complainant 1] and [Complainant 2] Respondent: [Financial Services Provider] Following the issuance
More informationG A U D A L R IN A E G NTE O E E F S H ACI E L R ITE
CASH COVER INDEMNITY HEADLINE GUARANTEE GOES FACILITY HERE ADDITIONAL DESCRIPTION DATE TERMS AND CONDITIONS 09.2017 CONTENTS 1. Indemnity Guarantee Facility 2 1.1 Application of these Terms and Conditions.
More informationSee article 36A4 of The Financial Services and Markets Act 2000 (Regulated Activities) Order 2001, S.I. 2001/544. 2
SERVICE-SPECIFIC GUIDANCE NOTE Consumer Credit Who should read this? As at October 2014, the Phone-paid Services Authority notes that the primary providers of consumer credit services in the premium rate
More informationHome Insurance. Privacy Notice
Home Insurance Privacy Notice Contents Introduction 3 What sort of data do Tesco Bank and the Tesco Bank Providers hold about you? 4 What about joint applications and insured persons? 5 How do Tesco Bank
More informationFacility Agreement Continuing Credit Facility - Line of Credit Terms & Conditions
Facility Agreement Continuing Credit Facility - Line of Credit Terms & Conditions Version 2, March 2013 Contents Section 1 Section 2 LINE OF CREDIT....1 DRAWDOWNS... 1 Section 3 REPAYMENTS........1 Section
More informationEquity Release. A guide to our Lifetime Mortgage products
Equity Release A guide to our Lifetime Mortgage products Introducing Retirement Advantage 2 A guide to our Lifetime Mortgage products Retirement Advantage is a wellestablished company that can trace its
More informationforeword 2 about us /2017 our year so far 5 2 our plans for 2017/ our proposed budget for 2017/
0 contents foreword 2 about us 4 1 2016/2017 our year so far 5 2 our plans for 2017/2018 12 3 our proposed budget for 2017/2018 25 annexes A historic incoming case volumes 31 B our projections for new
More informationFLA. Lending Code setting standards, creating transparency YEARS
FLA Lending Code 2017 25 YEARS setting standards, creating transparency KEY Each type of loan within this document is represented by the following colours: Loans taken out through a supplier of goods and
More informationDebt Clear Solutions Information Pack
Debt Clear Solutions Information Pack In these challenging and uncertain economic times, Debt Clear Solutions has recognised the growing need for a complete debt solution package for our clients one that
More informationINSURANCE: NEW CONDUCT OF BUSINESS SOURCEBOOK INSTRUMENT 2007
FSA 2007/67 INSURANCE: NEW CONDUCT OF BUSINESS SOURCEBOOK INSTRUMENT 2007 Powers exercised A. The Financial Services Authority makes this instrument in the exercise of the powers and related provisions
More informationPower of Attorney Application to Appoint an Attorney to Operate an Account(s)
Power of Attorney Application to Appoint an Attorney to Operate an Account(s) Please complete this form using black ink and BLOCK CAPITALS and return it together with and any proofs of identity/residency,
More informationCP14/06 - Regulated fees and levies: Rates proposals 2014/15
CP14/06 - Regulated fees and levies: Rates proposals 2014/15 This response is submitted on behalf of the Association of Mortgage Intermediaries (AMI). AMI is the trade association representing over 80%
More informationFreephone
1 of 8 07/02/2017 12:58 Complaints handling procedure Make a payment Request a call back Freephone 0800 051 5451 Menu Terms and Conditions Mis-Sold Payment Protection Insurance Terms and Conditions 1.
More informationFuture regulatory treatment of CCA regulated first charge mortgages
Financial Conduct Authority Future regulatory treatment of CCA regulated first charge mortgages November 2015 Consultation Paper CP15/36* Future regulatory treatment of CCA regulated first charge mortgages
More informationClaims Management Services Regulation. Conduct of Authorised Persons Rules 2013
Claims Management Services Regulation Conduct of Authorised Persons Rules 2013 Amended on 1 April 2013 Contents Introduction 1 Definitions 1 General Rules Principles 2 Conduct of Business 2 Professional
More informationCapital Gains Tax: Payment window for residential property gains. Comments from Saffery Champness LLP
Capital Gains Tax: Payment window for residential property gains Comments from Saffery Champness LLP 6 June 2018 Contents Page 1. Executive summary... 3 2. General points... 3 3. Specific consultation
More informationConsumer Credit sourcebook. Chapter 8. Debt advice
Consumer Credit sourcebook Chapter Debt advice CONC : Debt advice Section.1 : Application.1 Application.1.1 This chapter applies, unless otherwise stated in or in relation to a rule to every firm with
More informationThe Information Commissioner s response to the Financial Conduct Authority s call for inputs on big data in retail general insurance
The Information Commissioner s response to the Financial Conduct Authority s call for inputs on big data in retail general insurance 1. The Information Commissioner has responsibility for promoting and
More informationBREXIT AND DATA PROTECTION Q & A
BREXIT AND DATA PROTECTION Q & A What happens now? The UK decision to leave the EU will not affect existing data protection and privacy laws in the UK. These laws (the UK Data Protection Act 1998 (DPA)
More informationClaims Management Regulation Consultation Response
Claims Management Regulation Consultation Response Cutting the costs for consumers Financial Claims This response is published on 15 November 2017 In substitution of a previous version Response to consultation
More informationFinancial Ombudsman Service s consultation transparency and the Financial Ombudsman Service publishing ombudsman decisions: next steps
Financial Ombudsman Service s consultation transparency and the Financial Ombudsman Service publishing ombudsman decisions: next steps The UK Insurance Industry 1. The UK insurance industry is the third
More informationStrengthening Consumer Redress in the Housing Market. Executive Summary
Which?, 2 Marylebone Road, London, NW1 4DF Date: 16/04/2018 Response to: Strengthening Consumer Redress in the Housing Market Social Housing Division Ministry of Housing, Communities and Local Government
More informationBank of Ireland Insurance Services Limited. Terms of Business
Bank of Ireland Insurance Services Limited Terms of Business Our legal name is Bank of Ireland Insurance Services Limited Contact Details 4th Floor, Block B, Baggot Plaza 27-33 Upper Baggot St Dublin 4,
More informationFor commission eligibility and FCA product sales data purposes: if you did not provide advice on this sale please tick
M&G OEIC funds Application to invest a lump sum KIID Important Information: Before investing, you should read an up-to-date version of the Key Investor Information Documents (KIIDs) for the fund(s) in
More informationFor commission eligibility and FCA product sales data purposes: if you did not provide advice on this sale please tick. FCA number
The M&G ISA Application to transfer your ISA(s) to M&G from another ISA manager KIID MGSL This form can be used to: transfer both previous and current tax year ISA contributions to M&G from another ISA
More informationConsultation response
Consultation response SRA: Regulation of consumer credit activities Overview 1. Regulation of consumer credit activities is specialised and complex. Credit activities (and in particular debt collection)
More informationThe Motor Industry Code of Practice for. New Cars. TheMotorOmbudsman.org
The Motor Industry Code of Practice for New Cars. Contents Introduction 3 Definitions 5 Advertising 6 What this commitment means to you We would advise you to New Car Provisions 8 What this commitment
More informationSCHEDULE. a) Customer Letter means the letter to be sent to every Debt Consolidation Mortgage Customer as defined in paragraph 3.
From: The Mortgage Matters Partnership (FRN: 306863) Of: 8 Stockport Road Altrincham Cheshire WA15 8ET To: Financial Conduct Authority ( the FCA ) Date: 31 July 2017 VOLUNTARY APPLICATION FOR IMPOSITION
More informationHow The Mortgage Works and Nationwide use your information
How The Mortgage Works and Nationwide use your information For more information, please speak to your financial adviser or call our Customer Service Centre on 08000 30 40 60 Introduction This privacy statement
More informationFactsheet No. 2 Complaints and External Dispute Resolution (EDR)
Factsheet No. 2 Complaints and External Dispute Resolution (EDR) This factsheet answers some questions about making a complaint if you are unhappy about or have a dispute with a business or government
More informationThe contract is important so that both parties understand their responsibilities and liabilities.
Contracts At a glance Whenever a controller uses a processor it needs to have a written contract in place. The contract is important so that both parties understand their responsibilities and liabilities.
More informationWHO IS RESPONSIBLE FOR LOOKING AFTER YOUR PERSONAL DATA?
OVERVIEW of this Policy and Commitments to Privacy within Dual At Dual ("we", "us", "our"), we regularly collect and use information which may identify individuals ("personal data"), including insured
More informationApplication for a life assurance plan on the life of another person
Application for a life assurance plan on the life of another person Before completing this form, please read this information carefully. This form is for use where the applicant wishes to take out a plan
More informationSTEP STAGE WHAT IS INVOLVED
Client Agreement-Mortgage and Protection INTRODUCTION This agreement sets out the terms under which our services are to be provided, including details of the specific services and a summary of our charges
More informationIn producing this updated guide, our aim is that the relationships in which lenders and intermediaries are engaged deliver good customer outcomes.
1 Working together Working Together; An Industry Guide to Lender and Intermediary Accountabilities and Responsibilities in Mortgage Sales and Servicing revised and updated, April 2014 A Joint AMI, IMLA
More informationwhat we ve seen uncertainty April 2016 rise in foreign currency complaints 31%
Financial Ombudsman Service annual review 2016/2017 what we ve seen uncertainty Over the years we ve seen how political and economic events can affect how people feel about their finances making them more
More informationGuidance for ADR Applicants - updated CAP 1324
Guidance for ADR Applicants - updated CAP 1324 Published by the Civil Aviation Authority 2016 Civil Aviation Authority, CAA House, 45-59 Kingsway London WC2B 6TE You can copy and use this text but please
More informationTerms of business for conveyancing
Terms of business for conveyancing We have prepared this document to make our terms and conditions of business as clear and understandable as possible, and to anticipate, as best we can, any queries you
More informationBaker Hudson Independent Financial Advisers. Client Agreement
Baker Hudson Independent Financial Advisers Client Agreement Our aim at Baker Hudson is simple: Help you make the right financial choices. Baker Hudson Independent Financial Advisers Introduction Our aim
More informationSummary 2. Fixed-Odds Betting Terminals APPG: Resolution letter 3 Letter from the Commissioner to Mr Malcolm George, 2 May
RECTIFICATION 1 Contents Summary 2 Fixed-Odds Betting Terminals APPG: Resolution letter 3 Letter from the Commissioner to Mr Malcolm George, 2 May 17 3 1 Written evidence 6 1. Letter from Mr M George to
More informationOUR RELEVANT LIFE PLAN
KEY FACTS OF OUR RELEVANT LIFE PLAN January 2018 Important information you should read Protection Relevant Life WHAT S INSIDE See if our plan is right for you 3 The aims of our plan 3 Your commitment 4
More informationThe ban on referral fees in personal injury cases
The ban on referral fees in personal injury cases Response of Browne Jacobson LLP to consultation of 23 October 2012. L7181574001 Contents Executive Summary... 3 Contact details... 3 Introduction... 4
More informationOur Client Agreement and Statement of Services and Remuneration for Trustees
The Independent Life & Pensions Group Ltd 3 Adelaide House, Corbygate Business Park, Priors Haw Road, Corby, Northants, NN17 5JG Tel: 01536 443200 Email: hello@ilpg.co.uk Web: www.ilpg.co.uk Our Client
More informationImportant Consultation - FCA approach to SMEs as users of financial services
Important Consultation - FCA approach to SMEs as users of financial services The financial regulator, the FCA, is currently consulting on whether there is adequate protection for small and medium sized
More informationM&G Adviser reference number
The M&G ISA Application for tax year ending 5 April 20 Y Y KIID MGSL This form: can be used to invest in The M&G ISA for the first time can be used to make an additional subscription to your M&G ISA, and
More informationGrowth Product Plan G407
Structured Investments Growth Product Plan G407 Structured Investment Plan G407 FTSE 100 Enhanced Growth Plan October 2017 Royal Bank of Canada 6 year investment term FTSE 100 68% potential growth at maturity
More informationAssessment report. Kevin Dunion Scottish Information Commissioner. Kinburn Castle Doubledykes Road St Andrews KY16 9DS Tel:
Assessment report Scottish public authority: Transport Scotland Dates of on-site assessment: 24 and 25 February 2010 Assessors from OSIC: Claire Sigsworth and Avril Mills Date of publication: 25 August
More informationFINANCIAL PLANNING FINANCIAL SERVICES GUIDE Part 1
FINANCIAL PLANNING FINANCIAL SERVICES GUIDE Part 1 Date of issue 30 May 2014 (v8.0) Authorised Representative of InterPrac Financial Planning Pty Ltd ABN 14 076 093 680 Australian Financial Services Licence
More informationWorking With You: Broker Guide. Get started. UK guide January 2015
1/ Working With You: Broker Guide Get started UK guide January 2015 Intro Contents Glossary Legal disclaimer Welcome 01/ We ve been providing premium finance facilities for almost four decades now, and
More informationFCA Consultation CP 13/10 December 2013 The ABI s response to proposals for the FCA regime for consumer credit
FCA Consultation CP 13/10 December 2013 The ABI s response to proposals for the FCA regime for consumer credit The ABI is the voice of insurance, representing the general insurance, protection, investment
More informationFINANCIAL PLANNING FINANCIAL SERVICES GUIDE Part 1
FINANCIAL PLANNING FINANCIAL SERVICES GUIDE Part 1 Date of issue 30 June 2018 (v10.0) InterPrac Financial Planning Pty Ltd ABN 14 076 093 680 Australian Financial Services Licence Number: 246638 Level
More informationGDPR: The future of marketing and commercialisation of data. Alexander Brown & Matt Dyer, Simmons & Simmons
GDPR: The future of marketing and commercialisation of data Alexander Brown & Matt Dyer, Simmons & Simmons 18 May 2017 Fair and lawful processing Consents and notices Fair and lawful processing Personal
More informationI issued a provisional decision in September 2013 concluding that Mr A s complaint should be upheld.
complaint Mr A s complaint, in summary, is that Lighthouse Advisory Services Limited advised him to invest in a carbon trading partnership scheme (CTP) that was unsuitable for him. background I issued
More informationFINANCIAL PLANNING FINANCIAL SERVICES GUIDE (Part 1) Date of issue 1 November Version 11.0
FINANCIAL PLANNING FINANCIAL SERVICES GUIDE (Part 1) Date of issue 1 November 2018 - Version 11.0 InterPrac Financial Planning Pty Ltd ABN 14 076 093 680 Australian Financial Services Licence Number: 246638
More informationUse your property to your advantage. A guide to our Buy-to-Let products
Use your property to your advantage A guide to our Buy-to-Let products Introducing Retirement Advantage 2 A guide to our Buy-to-Let products Retirement Advantage is a wellestablished company that can trace
More information